Modern Slavery Act Statement 2024

This statement is made by PA Consulting Group Limited pursuant to clause 54, Part 6 of the UK Modern Slavery Act 2015 and applies to the UK business of PA Consulting group, which includes PA Consulting Services Limited and PA Holdings Limited.

At PA Consulting Group (PA) we prize our ethical approach and are committed to complying with all laws and regulations applicable to our operations, including taking steps to ensure that there is no human trafficking or slavery in our supply chain, or within any part of our business.

About our organisation

We are an innovation and transformation consultancy with more than 4,000 specialists in consumer and manufacturing, defence and security, energy and utilities, financial services, government and public services, health and life sciences, and transport. Our people are strategists, innovators, designers, consultants, digital experts, scientists, engineers and technologists. We operate globally from offices across the UK, Ireland, US, Netherlands and Nordics.

PA Consulting Group Limited is the parent company of the PA Consulting group of companies. Our principal operating subsidiary in the UK is PA Consulting Services Limited. PA Consulting Services Limited provides a range of consultancy services to clients, which are delivered by employees of PA Consulting Services Limited and PA Holdings Limited.

Our assessment of the risk of modern slavery in our operations and supply chains

We believe that due to the nature of our business and the services that we provide to our clients, the markets in which we operate, the nature of the goods and services which we procure, the locations from which we procure them, and our procurement practices, the risk of human trafficking or slavery occurring in our business or in our supply chain is low.

Notwithstanding this, we are committed to continual improvement in managing human rights and modern slavery risk in our supply chain, and we review our policies and procedures and assess the risks within our business and supply chain regularly.

Our core values

Our success as an innovation and transformation consultancy is founded on a set of core values: inspired by client value, passionate about people, achieving success through shared endeavours, prizing our ethical approach, seeking to excel and creating commercial success.

These core values commit PA and every one of our people to environmental stewardship, safe work environments and socially responsible behaviour in our workplaces and in our communities, as well as in the consulting services we provide to our clients.

Our code of conduct and our corporate social responsibility policy are based on our core values. They drive the way we behave and govern our conduct towards our people, our suppliers, and our wider stakeholder community.

Our employment practices

At PA we are committed to the equal treatment of all, and we treat all our people with dignity and respect, providing a productive working environment free from discrimination, victimisation, coercive pressure, bullying and harassment.

We are a UK Living Wage accredited employer, and we use only specified, reputable employment agencies to source labour and verify the practices of any new agency before accepting workers from that agency.

Since 2007 we have been a member of the UN Global Compact, a strategic policy initiative for business that aims to align members’ operations and strategies with the internationally accepted principles relating to human rights, labour, the environment and anti-corruption.

PA also complies with the Ethical Trading Initiative (ETI) base code, which is founded on the conventions of the International Labour Organisation and is an internationally recognised code of good labour practice. The minimum standard provisions of the ETI base code are: employment is freely chosen; conditions are safe and hygienic; no child labour is used; living wages are paid; working hours are not excessive; no discrimination is practiced; regular employment is provided; and no harsh or inhumane treatment is allowed.

Our approach to supplier selection

PA chooses suppliers on the basis of fair and transparent principles, and it encourages its suppliers to adopt best practices in terms of human rights and diversity; it assesses this through its supplier information request form which includes mandatory sections on its compliance with relevant laws and regulations, including those relating to human rights and modern slavery. PA also asks its suppliers to agree to PA’s supplier code of conduct, or to provide their own code of conduct which must meet PA’s minimum standards.

As part of our supplier identification and onboarding process, we review suppliers based on the following criteria:

• Do not have operations in, or source goods or services from, high-risk countries, as identified in the Walk Free Global Slavery Index as those where modern forms of slavery or human trafficking are more likely to occur.
• Have taken adequate steps to ensure that slavery and human trafficking are not taking place within their business or supply chain.
• Have, if applicable, published a slavery and human trafficking statement for the current financial year.
• Have adequate policies and systems to prevent the use of illegally or unethically sourced materials, and prevent improper procurement of conflict materials.
• Have adequate procedures in place to prevent bribery.
• Are committed to high labour standards, including ensuring fair working hours.
• Are an accredited Living Wage employer, who pay all directly employed staff at or above the currently established real Living Wage.
• Have certain social standard accreditations, such as SA8000 or ISO26000.
• Have a documented Diversity and/or Equal Opportunities policy.

In addition, PA carries out an annual review of its supply chain by mapping its suppliers to identify those that are operating in higher risks countries or sectors. The mapping exercise is carried out using the Walk Free Global Slavery index report which provides information on higher risk countries and sectors, which we map against our own supplier data to identify where further due diligence may be required.

Training and engagement

At PA we recognise the importance of stakeholder engagement. Our commitments and actions in combatting modern slavery have been communicated to the relevant entities and functions within PA and we have ensured that relevant areas of PA are aware of what actions need to be taken to identify, assess, and address modern slavery risks in our operations and supply chains. All PA staff undertake mandatory annual training and an assessment on PA’s code of conduct and the group-wide policies and procedures that they must comply with in order to work at PA.

We encourage people across PA to take active responsibility for improving our performance and practices and for drawing attention to behaviours or other issues that give them concern. To encourage feedback and suggestions, PA has procedures and mechanisms to create a culture that allows people to speak up with confidence and in good faith in the expectation of being heard.

Our people and third parties are able to raise concerns anonymously through a confidential whistle blowing helpline that is operated by an external firm. Third parties, including clients and suppliers, can similarly provide feedback (anonymously or named) through PA’s external website.

This statement was approved by the boards of PA Consulting Group Limited, PA Consulting Services Limited and PA Holdings Limited on 19 June 2024.

Christian Norris
Chief Executive Officer
PA Consulting